he appropriate valuation date of marital property in a bifurcated dissolution hearing is the date of trial under the Illinois Marriage and Dissolution Act, according to a November 9, 2011, Illinois Fourth District Appellate Court ruling.

The court found that, despite Petitioner Kristina Baniak's claims, the lower court had subject matter jurisdiction to hear the case regarding attorney's fees and that Baniak had waived all other issues raised in her appeal.

On October 23, 2009, the Illinois Appellate Court, Fifth District, affirmed in part and reversed in part the decision of the Circuit Court of St. Clair County to grant defendant's motion to dismiss a complaint relating to the release of mental health records in a divorce proceeding.